Obrót „pustymi fakturami” jako przesłanka uzasadniająca zabezpieczenie wykonania zobowiązania podatkowego
“Blank invoices” circulation as a prerequisite justifying securing tax liability performance

Summary/Abstract: Herein, the Authors presented the issue of using tax liability security institutions together with interests on asset components against entities participating in carousel frauds. The conducted analysis indicated that the contents of Art. 33 of the Tax Ordinance constitute a substantive legal basis for using tax liability security institution on the taxpayer’s asset components prior to issuing a decision stipulating the liability in the case of circulating “blank invoices”, which do not reflect the actual character of concluded business transactions. Documentation drawn up by entities participating in circulation of “blank invoices” issued to fictitious economic events confirms justified concern of not paying anticipated tax liability and this argument increases in meaning even more, if the amount of anticipated tax liabilities is taken into consideration.

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